A while ago, I mulled on the meaning on the phrase “due diligence”. My mullings came back to bite me this week as I leafed through the Spectator magazine and spotted Dot Wordsworth’s column. Dot writes about the sources, meanings and etymology of words, and she has finally tackled “due diligence”. As I did, she quickly spotted that the phrase has devotional roots, but notes that it is now used to mean checks done ahead of a course of action – often the purchase of a business, as in her example, but in our AML arena, more commonly the taking on of new clients (or of new activity by existing clients).

What caught my eye about Dot’s musings was her observation that “if you don’t do your due diligence, you deserve to be stung”. I certainly think that this attitude is common with AML: if you don’t do the sensible checks, you have only yourself to blame if (when) you end up laundering money and/or being fined by the regulator for your lackadaisical attitude.

3 Responses to DD dire warnings

PS Who is to saythe EA did not make a SAR? they would have been potentially tipping off C4 if they had so your assumption that no SAR was made is unsubstantiated.
PS this and the earlier reply are on the wrong blog post

Dear John
Welcome to the blog, and thank you for your comments.
It’s a fair point you make about the programme not being able to say for certain whether a SAR was made or not – but I assume that C4’s lawyers had a good look at what the investigative journalists had uncovered and what they were implying. Also, the wording of the responses from the estate agency companies involved suggest – although, as you say, do not confirm – that SARs were not made.
SARs aside, it is not acceptable for the estate agents to engage in discussions with Boris about how he can circumvent due diligence checks and what he should admit to any lawyer who may ask questions.
Best wishes from Susan

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